Read Our Scoping Comments
May 21, 2018
Matthew M. McCombs Gunnison District Ranger 216 N. Colorado Gunnison, CO 81230
Electronic submission to: https://www.fs.usda.gov/project/?project=53662
Re: Taylor Park Vegetation Management Project Scoping Comments
Dear Matt,
The following are the comments of High Country Conservation Advocates (HCCA), The Wilderness Society, Western Colorado Congress, Wilderness Workshop, Rocky Mountain Wild, Great Old Broads for Wilderness, Wild Connections, Center for Biological Diversity, Rocky Smith, and Tim and Sheri Murphy (property owners adjacent to the project site) on the proposed Taylor Park Vegetation Management Project, as described in the Scoping Letter of April 19, 2018, the Proposed Vegetation Treatment Details, and Design Features. Thank you for the opportunity to comment on this proposal.
I. PREPARE AN ENVIRONMENTAL IMPACT STATEMENT Under the proposed project, 15,165 acres could be treated.1 Strips up to 300 feet wide or even larger could be created,2 and might have to be permanent to serve their purpose. (See further discussion below in section V.) This would considerably fragment wildlife habitat for species needing forested habitat, including lynx and marten. It would also affect recreation, watersheds, soils, scenery, and other resources. Overall, such treatment could have significant effects on the human environment. Thus an EIS must be prepared.
II. FORMULATE AND ANALYZE ADDITIONAL ALTERNATIVES THAT MEET THE PROJECT’S PURPOSE AND NEED WHILE REDUCING THE IMPACTS Under HFRA,3 the agency is only required to analyze the proposed action and no action alternatives, but others can be proposed by commenters during scoping. Any alternative proposed must meet the project’s purpose and need. The undersigned organizations and individuals request that the Forest Service prepare additional alternatives, beyond the contemplated all-or-nothing approach, that would still meet at least part of the project’s purpose and need while significantly reducing environmental impacts. One alternative should propose treatments only, or at least primarily, in the highest priority areas, as described below. A second alternative should prioritize treatment areas outside of those identified for conservation by recent and ongoing community endeavors, also described below. (We are
1 Scoping Letter, at 3. [Hereinafter SL] 2 Proposed Vegetation Treatment Details, at 2. [Hereinafter PVTD] 3 16 U.S.C. 6516(c)(1)(C).
happy to see that no treatments would be proposed in wilderness areas, wilderness study areas, Colorado Roadless Areas, and designated recreation management areas.)4
It would be impossible, and unnecessary, to treat every acre currently affected or possibly affected in the future by dwarf mistletoe, bark beetles, or other natural forest stressors. Therefore, treatments should be located where they will do the most good to protect public safety while maintaining favorable ecological conditions and causing the least adverse impacts to various resources. Accordingly, we request that the Forest Service analyze an alternative that limits timber cutting to the highest priority areas, identified as:
(1) the wildland urban interface (WUI)5; (2) along roads that access private land and/or roads frequently used by the public and the Forest Service for access to the Gunnison National Forest; (3) in and adjacent to campgrounds, picnic grounds, trailheads, and other sites used by the public; (4) along powerlines.
Alternatives that would treat less acreage and produce a lower volume would still meet the project’s purpose and need, as they would still address the primary purpose to “respond to multiple and interactive stressors affecting the forest including climate change, drought, insect attack and disease while promoting safety through reduction of fuel loading in the Wildland-Urban Interface (WUI) and surrounding areas” and the secondary purpose “to provide wood products for the regional economy.”6 Regarding the latter purpose, the Gunnison National Forest has already approved tens of thousands of acres of resiliency treatments through SBEADMR, and the regional economy receives wood products from that project (and others). A scaled-back Taylor Park project could “complement”7 SBEADMR without resulting in 15,000 acres of additional logging, new road construction, and associated impacts.
The Forest Service needs to clearly define and substantiate its definition of WUI. While there are various definitions, some of these tend to be overly liberal, allowing for excessive wildlands fuels management. The undersigned suggest that a much more limited WUI be used for this project, preferably a 200-foot treatment buffer surrounding structures.8 We ask that the project clarify its WUI definition to allow for more effective, and less intrusive, forest management. Areas that are much beyond 200-feet from a community or other infrastructure are not part of a WUI, and treatment to protect the infrastructure is not needed there.
4 SL, at 3. 5 In this case, the WUI should extend no more than about 200 feet from infrastructure. 6 Forest Service News Release, April 18, 2018. 7 Id. 8 Cohen, Jack D., 1999. Reducing the Wildland Fire Threat to Homes: Where and How Much? In: Proceedings of the Symposium on Fire Economics, Planning, and Policy: Bottom Lines, April 5-9, 1999 San Diego, California. USDA Forest Service General Technical Report PSW-GTR-173, at 192: “SIAM modeling, crown fire experiments, and W-UI fire case studies show that effective fuel modification for reducing potential W-UI fire losses need only occur within a few tens of meters from a home, not hundreds of meters or more from a home.” Available at https://www.fs.usda.gov/treesearch/pubs/5603. Attachment 1. The Forest Service should fully consider an alternative that includes a reasonable WUI area plus a safety margin for firefighters. Forest Service research clearly shows that the best way to protect structures from wildfire is to treat the structure itself and the area immediately surrounding it.9
The most important areas to treat are those where mortality caused by mistletoe infestation and bark beetles poses a risk to public health and safety. A component of the stated purpose and need is “promoting safety through reduction of fuel loading in the [WUI] and surrounding areas.”10 As discussed above, treatment in the WUI is an important part of meeting that purpose. But another aspect of safety stems from dead, dying, or infected trees adjacent to human infrastructure. It thus would be appropriate to remove some dead and dying trees along roads that access private land and/or are used by the public and the Forest Service for access to the Gunnison National Forest.
The Taylor Park area is one of the most heavily-utilized and impacted areas on the Gunnison Ranger District in terms of recreational use. Removal of dead and dying trees from developed and dispersed campgrounds, picnic grounds, trailheads, and other sites used by the public should thus be top priority, taking precedence over remote areas far away from human use. Treatments should not be more than is necessary to protect the respective infrastructure. For example, hazard tree removal along roads should occur no more in distance from the road than the height of the tallest tree in the stand plus about 10 percent. Ensuring that infected trees will not hit power lines should also be among the top priority treatments in the Taylor Park area.
The undersigned also request that the Forest Service consider an alternative that prioritizes treatments outside of areas identified by past and current community public lands endeavors for wilderness designation, special management area designation, and roadless area conservation. There is a long track record of local support for public lands conservation in and around the project area. In 2005, a local initiative known as Mountains to Mesas (or M2M) submitted comprehensive wilderness recommendations as part of the previous, but ultimately abandoned, GMUG National Forest plan revision process. Developed by citizens and scientists in western Colorado in collaboration with HCCA, Sheep Mountain Alliance, Southern Rockies Ecosystem Project, Western Colorado Congress, and Western Slope Conservation Center, M2M recommended 21,016 acres at Matchless Mountain for wilderness.11
In addition, the 2001 Roadless Area Conservation Rule identified 34,100 acres for roadless protection at Matchless Mountain. The 2001 Roadless Rule used inventoried roadless areas from forest plans that were in effect at the time the 2001 Rule was developed, or a roadless inventory that had undergone public involvement. However, large areas to the north of Matchless Mountain were removed by the GMUG’s 2005 roadless area re-inventory, and the subsequent Colorado Roadless Rule rulemaking process removed significant acreage on Matchless Mountain from its final inventory, over the objection of HCCA and others. As part of the development of the Colorado Roadless Rule, in 2011 the Southern Rockies Conservation Alliance (or SRCA – an umbrella organization for approximately 25 Colorado-based
9 Id. See also Cohen, Jack, 2008. The Wildland-Urban Interface Fire Problem, A Consequence Of The Fire Exclusion Paradigm. Forest History Today (Fall 2008). Attachment 2. 10 SL, at 2. 11 See Attachment 3. conservation organizations, including HCCA), identified and recommended 42,800 acres for roadless protection at Matchless.12 These areas remain largely unroaded.
There appears to be project overlap with roadless forest at Park Cone. The 2001 Roadless Rule Inventory of the 20,000-acre Crystal Creek area includes the Park Cone area. The SRCA inventory of this area found 6,500 acres.13 The final Colorado Roadless Rule eliminated altogether the Park Cone area from its inventory. The Park Cone roadless area is bounded on the north and west by County road 742, on the south by private land along Lottis Creek, and on the east by forest road 752. The 12,100-foot symmetrical Park Cone peak is practically an island surrounded by Taylor Reservoir, Taylor River, Lottis Creek and its unnamed tributaries through Union Park. Although this is a relatively low summit, there is a significant distance between its low and high elevations giving it good prominence within the surrounding area. Potential habitat for lynx is found in this area. Opportunities for recreation in this area include visiting it from the nearby Lakeview campground and off-trail hiking to a prominent peak. HCCA and other groups advocated for the roadlessness of this area in 2011, and it remains largely unroaded.14
It also appears that there is project overlap with roadless forest at Red Mountain Creek. The SRCA inventory of this area found 4,900 acres. 15 The 2001 Roadless Rule Inventory found 3,900 roadless areas in the Red Mountain Creek area, part of the area named Elk Mountains – Collegiate. The Red Mountain Creek area was not included in the Colorado Roadless Rule inventory. The Red Mountain Creek area is bounded on the north and northeast by the Collegiate Peaks Wilderness Area, on the west and southwest by forest road 742 along the Taylor River and on the east by forest road 742.3D along Pieplant Creek. HCCA and other groups advocated for the roadlessness of this area in 2011, and it remains largely unroaded.16
In addition, an ongoing community public lands legislative effort, the Gunnison Public Lands Initiative (GPLI), includes acreage in its initial proposal that overlaps with the proposed project.17 This includes the recommended Matchless Wilderness and the recommended Crystal Creek addition to the Fossil Ridge Wilderness. There is also project overlap with GPLI recommended special management areas (SMAs), including American Flag, Matchless, and Union Park. Each of the above areas is included in the GPLI Working Group for Public Lands Initial Report, which was released to the public in June of 2017 after a year-and-a-half of stakeholder meetings.18
12 See Colorado Roadless Area Conservation, National Forest System Lands Proposed Rule and Revised Draft EIS, Summary of Public Comment, NSG NEPA Services Group (September 2011), at 4-67. Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5366317.pdf. 13 Id. at 4-33. 14 Id. 15 Id. 16 Id. 17 See https://www.gunnisonpubliclands.org/explore-the-map/. 18 See https://static1.squarespace.com/static/53973ed8e4b0ac2dcfe3932c/t/5a3959af71c10b916d2aacc0/1513707961656/ WG+Report+-+17.12.5+-+small.pdf. Proposed treatments on the northern and northeastern aspects of Matchless Mountain are of particular concern to the undersigned. Matchless is a rugged and steep landscape offering opportunities for solitude within a part of the Gunnison National Forest seeing increased recreation pressure. Rising dramatically above Taylor Canyon, views from the area include Taylor Park, the Collegiate Range, and the Three Apostles. While rising above the popular recreation areas of Taylor Reservoir and the Taylor River, Matchless retains a high degree of naturalness. The rocky walls of Taylor Canyon turn to conifer- covered slopes rising to alpine habitat. These mid- to higher-elevation forests provide good habitat for lynx, elk, goshawk and pine marten. Much of the area is very steep and rugged.
To reiterate, the lands encompassed in the proposed project area are loved by many locals and visitors alike, and are home to a wide variety of non-consumptive uses. They also provide outstanding wildlife habitat and wildlife refuges in an area witnessing increased recreational pressure from a variety of users. Diverse forms of recreation are popular in project area, including hiking, snowshoeing, hunting, fishing, mountain biking, and motorized use. Widespread logging that results in significant clearcuts has the potential to negatively impact multiple recreation experiences. Fifteen thousand acres of timber treatment, new road construction, and industrial equipment on the landscape could significantly and adversely impact established uses, wildlife habitat integrity and connectivity, and the lives of property owners in the vicinity. An alternative that strikes a compromise between the Forest Service’s proposed action on the one hand, and doing nothing on the other hand, would satisfy the expectations of multiple community interests while still meeting the project’s stated purpose and need.
III. ANALYZE CUMULATIVE IMPACTS There have been many vegetation management/timber sale projects in and near the project area over the past decades. According to the Scoping Letter, 6,363 acres of lodgepole pine has been previously treated.19 There has likely been some treatment on Engelmann spruce stands also. Under the recently approved SBEADMR Project, 40,691 acres of spruce-fir and aspen in the Gunnison North Geographic Area could be treated.20 Some of this is in the Taylor Park project area. Compare the SBEADMR preferred alternative map21 with Taylor Park Scoping/Comment Map.
All of the past cutting, the acres approved under SBEADMR, and any other reasonably foreseeable future project must be considered along with the Taylor Park Project in determining the potential cumulative impacts to recreation, watershed, soils, scenery, etc., and most importantly, to wildlife habitat fragmentation and connectivity.
IV. RETAIN LARGE TREES The Scoping Letter states that the project “is eligible as an authorized project under [the Healthy Forest Restoration Act] because all treatments are in areas designated in accordance with section 602 of HFRA”.22 Projects authorized under HFRA must meet certain requirements, including large tree retention. Specifically, treatment in projects proposed under this act:
19 At 1. 20 SBEADMR ROD, at 5. 21 At FEIS G-3 22 At 2.
(A) focuses largely on small diameter trees, thinning, strategic fuel breaks, and prescribed fire to modify fire behavior, as measured by the projected reduction of uncharacteristically severe wildfire effects for the forest type (such as adverse soil impacts, tree mortality or other impacts); and
(B) maximizes the retention of large trees, as appropriate for the forest type, to the extent that the trees promote fire-resilient stands.23
As is discussed below in section VI, many trees in the project area are likely to have small diameter. Any larger diameter trees are thus very important, and need to be identified and retained.
V. THE PROPOSED DWARF MISTLETOE TREATMENT IS EXCESSIVE AND WOULD FRAGMENT WILDLIFE HABITAT. Dwarf mistletoe is known to be very beneficial to the forest ecosystem. For example, bird species richness increases considerably in stands with dwarf mistletoe.24 In fact:
Our data suggest that dwarf mistletoes may have a positive effect on wildlife habitat. Consequently, we suggest that eradication efforts be reconsidered given that dwarf mistletoes have been part of these forest ecosystems for thousands, and possibly millions, of years.25
Dwarf mistletoes attract various insects, including pollinators. This in turn attracts various predators.26
Under the type of treatment named “Dwarf Mistletoe Edge Strip Cuts and Dwarf Mistletoe Clearcut,” strips 100-300 feet wide adjacent to mistletoe-infected stands would be cleared (except for non- lodgepole pine and wildlife trees).27 This would be applied to 3,605 acres in the project area.28 These strips could be even wider if the residual strip between former clearcuts would leave only a “narrow strip of trees which would be vulnerable to windthrow,” in which case “the entire strip would be removed.”29
23 16 U.S.C. 6512(f)(1). 24 See Bennetts, Robert E., Gary C. White, Frank G. Hawksworth, and Scott E. Severs, 1996. The Influence of Dwarf Mistletoe on Bird Communities in Colorado Ponderosa Pine Forests. Ecological Applications 6(3), pp. 899-909. Attachment 4. 25 Id. 26 Geils, B. W., and F. G. Hawksworth, 2002. Damage, Effects, and Importance of Dwarf Mistletoes. In: Mistletoes of North American Conifers. USDA Forest Service, Brian W. Geils, Jose Cibrián Tova, and Benjamin Moody, technical coordinators. General Technical Report RMRS-GTR-98, September 2002, at 62. Available at https://www.fs.fed.us/rm/pubs/rmrs_gtr098/rmrs_gtr098_057_065.pdf. 27 PVTD, at 2. 28 SL, at 3. 29 PVTD, at 2. Additional “Dwarf Mistletoe Clearcut[s]” could be done in areas proposed for shelterwood seed cut if any stands are dominated by lodgepole pine and infected with mistletoe.30
If young stands are surrounded by mistletoe-infected stands, then at least some of the young trees are likely already infected with mistletoe. Depending on how old the “young” trees are (i. e., how long they have had to become infected), and how severe the infection in the surrounding overstory is, it may be too late to treat the surrounding stands to promote mistletoe-free younger stands. Stands may have mistletoe even if they do not show it, as the incubation period is 2-12 years, and typically 3-4 years, before shoots emerge.31
In any case, the proposed treatment is much more than would be needed to prevent or greatly reduce new infestation of the young stands, as mistletoe shoots only 50-75 feet, and “most seeds fall within 33 feet of the host tree or on other parts of the same tree.”32 This is confirmed by Hawksworth et al, 2002, who stated:
Although maximum horizontal displacement may reach 16 m [52.5 feet], 10 m [32.8 feet] is a more typical, free-flight distance . . . . Most seeds are displaced horizontally only 2 to 4 m and deposited lower in the crown . . . .33
Part of the strip might have to be permanently kept deforested to prevent infection of any regeneration from mistletoe-infected trees surrounding the cut strip. It would very undesirable to have young trees infected with mistletoe because:
Seedlings are especially vulnerable; a single mistletoe infection on the seedling is either lethal or so damaging the host sapling appears more like a bush than a tree.34
In other words, cutting strips would not be sufficient to reduce mistletoe, as they would have to be continually treated and left deforested. It seems that mistletoe control in a large area like Taylor Park that has long been had mistletoe throughout is futile. The scoping map shows the proposed mistletoe treatment areas throughout the project area, surrounding young stand pre-commercial or sanitation treatments. Thus there would be large areas with no trees on them in the project area if the project as currently proposed was implemented.
30 Id. at 3. 31 Hawksworth, F. G, D. Weins, and B. W. Geils, 2002. Arceuthobium in North America. In: Mistletoes of North American Conifers. USDA Forest Service, General Technical Report RMRS-GTR-98, September 2002, at 31. Available at https://www.fs.fed.us/rm/pubs/rmrs_gtr098.pdf. 32 SL, at 1. 33 At 30 (citation omitted). 34 Geils and Hawksworth, 2002, at 58. The 300 foot width is the opening size that begins to inhibit lynx movement.35 Squires et al, 2010, found that lynx in Montana “avoided recent clear-cuts or other open patches.”36 “In winter, lynx do not appear to hunt in openings . . . .”37 Other species needing forested habitat would also be adversely affected. For example, marten tend to avoid areas without overhead tree cover, including clearcuts.38 Some habitat for goshawk, boreal owl, golden-crowned kinglet, and olive-sided flycatcher could be eliminated by the proposed strip cuts.
Thinning young stands, which may be done under the proposed project,39 reduces the horizontal cover needed by snowshoe hare, lynx’ favorite prey. This could lead to a considerable reduction in hare.40 Even without any thinning, the numerous clearcut strips would reduce the quality of lynx habitat or even render some of it unsuitable, and could reduce habitat connectivity across the landscape and between and within lynx analysis units. That would violate the Southern Rockies Lynx Amendment (SRLA):41
Objective ALL Maintain or restore lynx habitat connectivity in and between LAUs, and in linkage areas.
Standard ALL S1 New or expanded permanent developments and vegetation management projects must maintain habitat connectivity in an LAU and/or linkage area.42
With all the previous treatment in and near the project area, additional treatment as proposed could also violate Standards Veg S1 and Veg S2, requiring, respectively, that no more than 30 percent of the lynx habitat in a lynx analysis unit (LAU) be in unsuitable condition and that no more that 15 percent of an LAU can be made unsuitable in any ten-year period.43
35 See Aubry, Keith B, Gary M. Koehler, and John R. Squires, 1999. Ecology of Canada Lynx in Southern Boreal Forests. In: Ecology and Conservation of Lynx in the United States. USDA Forest Service General Technical Report RMRS GTR-30WWW, October, 1999. Available at https://www.fs.usda.gov/treesearch/pubs/50636. 36 Squires, John R., Nicholas J. Decesare, Jay A. Kolbe, and Leonard F. Ruggiero, 2010. Seasonal Resource Selection of Canada Lynx in Managed Forests of the Northern Rocky Mountains. Journal of Wildlife Management 74(8):1648–1660; 2010; DOI: 10.2193/2009-184, at 1648. Available at https://www.fs.usda.gov/treesearch/pubs/50160. Attachment 5. 37 ILBT, 2013. Interagency Lynx Biology Team. 2013. Canada Lynx Conservation Assessment and Strategy. 3rd edition. USDA Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication R1-13-19, Missoula, MT. 128 pp. at 28; citations omitted. Available at https://www.fs.fed.us/biology/resources/pubs/wildlife/LCAS_revisedAugust2013.pdf. 38 Buskirk, Steven M., and Leonard F. Ruggiero, 1994. American Marten. In: The Scientific Basis for Conserving Forest Carnivores: American Marten, Fisher, Lynx, and Wolverine in the Western United States. USDA Forest Service, General Technical Report RM-254. Available at https://www.fs.fed.us/rm/pubs_rm/rm_gtr254.pdf. Marten is a sensitive species in Forest Service Region 2. 39 PVTD, at 4-5. 40 See ILBT, 2013, at 72-73. 41 This document, establishing forest plan objectives, standards, and guidelines for forest plans in Region 2, is formally titled “Southern Rockies Lynx Management Direction”. We use both names in our comments here. 42 Southern Rockies Lynx Management Direction (or SRLA), Record of Decision at Attachment 1-1. 43 See SRLA at Attachment 1-2, 1-3. Cutting trees reduces future dead and down logs, some of which form denning habitat for lynx. Where trees are cut, some logs should be retained for possible lynx denning habitat.44 Retaining down dead will also benefit other wildlife species and soils. Treatments in any area should avoid advance regeneration, except where it is the regeneration being treated. The young trees may provide, now or in the future, the dense horizontal cover needed by snowshoe hare, lynx’ favorite prey.
Overall, the impacts from implementing the mistletoe control treatments could be significant. If recent photos taken by HCCA staff of related treatments in the project area are indicative of things to come (see Attachment 6), the potential impacts of this project are troubling. Numerous and sizable forest openings would not be good for any species that needs forested habitat. The potential impacts to all species possibly present in the project area must be disclosed in the NEPA document prepared for the project, which, as discussed above in section I, should be an EIS. The NEPA document must demonstrate compliance with SRLA.
VI. IS TIMBER HEAVILY INFESTED WITH DWARF MISTLETOE MERCHANTABLE OR DESIRABLE TO INDUSTRY? Pages 1-2 of the Scoping Letter state that “[t]he best tool for removing the [dwarf mistletoe-] infected trees is through commercial timber harvest.” But how merchantable are these trees? Our perception is that they are rather small in diameter. This is consistent with stands that have long been infected with mistletoe and/or are severely infected, as mistletoe is known to reduce tree growth,45 with effects increasing as the infection becomes more severe.46
In any case, the small size of the trees reduces their possible utilization for wood products such as those manufactured at the Montrose Mill, the industry outlet most likely to bid on any large timber sales offered from the Taylor Park area.47 Trees heavily infested with dwarf mistletoe in the tree bole, as opposed to only in the braches, may be even less desirable for industry. As Geils and Hawksworth, 2002 stated:
Wood quality of mistletoe-infected trees is affected by production of larger knots, development of abnormal grain, reduced strength, and other altered physical and chemical properties.48
Mistletoe infections also provide entry points for decay fungi.49
44 See SRLA Guideline VEG G 11, SRLA ROD at Attachment 1-5 45 Even without dwarf mistletoe, most trees in Taylor Park area would not be expected to be very large due to the short growing season. 46 See Geils and Hawksworth, 2002, at 58. 47 Montrose Forest Products is clearly the largest buyer of GMUG timber, as it is “the purchaser of the majority of the GMUG’s large timber sales”, and it “processes most of the wood removed from the [GMUG]”. Revised Draft Timber and Vegetation Management Assessment (prepared for the GMUG management plan revision) at 2 and 12. 48 At 61. 49 Id. The GMUG NF is already offering much timber for sale, and will continue to do so, under SBEADMR and other projects. It is unclear how the quality of timber to be offered from these other sources compares with that in the Taylor Park Project area, but intuitively, trees from the latter area are less likely to be desired in terms of size and quality than live trees in other areas. It does not seem likely that all of the timber the GMUG could offer from the Taylor Park area – if the project is approved as currently proposed – could be purchased and harvested by industry.
VII. PROTECT RARE PLANTS AND FIGHT NOXIOUS WEEDS. Before any ground disturbing activities occur, areas within and adjacent to locations proposed for treatment or road building must first be surveyed for rare plant populations.50 Any such populations must be marked and protected with a no-disturbance buffer sufficient to allow the populations to expand. The proposed lower limit of this buffer, 20 feet in design feature FSSP-10, is insufficient. We believe 100 feet should be the minimum buffer. All kinds of weed treatment must be located to avoid rare plants.
The same surveys should identify noxious weeds. All such populations must be eradicated to the extent practicable before ground disturbance commences. Certainly, weed treatments in areas at high risk for weed infestation must eliminate much more than 50 percent of the weeds, contrary to proposed design feature IW-5. The goal should always be 100 percent eradication, even though it probably not possible to achieve full eradication.
Survey and eradication should continue for at least three full growing seasons after ground disturbing activities have been completed, and be conducted in and adjacent to all areas of ground disturbance, not just in the areas of high risk for weed.51
Design feature FSSP-6, prohibiting the use of mechanical equipment within 100 feet of fens, is good and should be retained.
VIII. PROTECT SOILS The use of heavy equipment for commercial timber harvest is likely to damage soils, by compacting or displacing them, especially at landings and on skid trails and temporary roads. Areas so affected should be repaired, but care must be taken not to damage tree roots that protrude from, or are near, the soil surface.
Areas with detrimental compaction, displacement, severe burning, or erosion must not be treated until the areas are recovered or mitigation measures have been successfully applied.52
50 These include endangered, threatened, proposed, candidate, sensitive, and local concern species. 51 See DF IW-3D. 52 See Soil Management Handbook, FSH 2509.18, R2 Supplement No. 2509.18-92-1, at 2.2 (4). In areas with insufficient down dead logs to meet the Forest Plan standards (see Plan at III-10), some material cut for the project should be retained to reduce soil erosion, slowly decay into new soil, and provide wildlife habitat. Existing down dead material should not be burned or removed. It should be allowed to decay in place.
IX. SLASH DISPOSAL There is no discussion of slash disposal in the PVDT, except for fuel treatments. For this type of treatment, “[r]esidual slash will be hand or machine piled and burned to reduce the intensity of a ground fire.”53 While some method(s) of slash treatment will need to be done, especially in areas near private land where fuel treatments are proposed, burning piles itself creates a high intensity ground fire. This would be particularly true for machine piles, which could be 10-15 feet high. Even if comprised of small material (say less than three inches in diameter), the result would be long-lasting fires that would sterilize soils and volatilize soil nutrients.
Burning piles as proposed might not comply with DF FSSP-10:
Conduct prescribed fires (broadcast and piles) to minimize the residence time on the soil while meeting the burn objectives . . . .
Landowners, their guests, and recreational users would not like the smoke produced by these fires, if burning occurred when they were present.
We recommend that the Forest Service consider other slash disposal methods for lands in the wildland- urban interface. Some slash should be retained to protect and renew soils. If slash is piled, it should be limited to hand piles composed of material three inches or less in diameter and no more than about four feet high. Burning should not occur in areas with weeds, like cheatgrass (Bromus tectorum), that proliferate and dominate after fires. DF IW-1 should be mandatory.
If slash is chipped, depth should be limited to about two inches and cover not more than about 15 percent of a unit. Chips would prevent vegetation from sprouting, and could consume a considerable amount of soil nitrogen during decomposition.
X. MINIMIZE WINDTHROW Removing trees may reduce the wind firmness of the stands where cutting takes place, leading to trees blowing down after cutting. Any spruce blowdown would be especially undesirable because spruce bark beetles breed heavily in such material. All cutting units must be carefully designed to minimize windthrow.
XI. CONCLUSION
53 PVDT, at 5. The proposed project is more than is needed to treat mistletoe, and would have possibly significant impacts to wildlife, recreation, and other resources. Therefore, we strongly recommend a much smaller project, one that would concentrate treatment in the wildland-urban interface. An EIS should be prepared that analyzes at least one additional alternative to the proposed action. The EIS should analyze and disclose potential cumulative impacts from the proposed project along with past projects, SBEADMR, and other reasonably foreseeable future projects. The undersigned reserve the right to supplement these scoping comments with additional information throughout the agency’s administrative process.
Thank you for your consideration of these comments.
Sincerely,
Matt Reed Rocky Smith Public Lands Director Forest Management Analyst & Consultant High Country Conservation Advocates 1030 Pearl #9 PO Box 1066 Denver, CO 80203 Crested Butte, CO 81224 (303) 839-5900 (303) 505-9917 [email protected] [email protected]
/for/
Steve Allerton Scott Miller President Senior Regional Director, Southwest Region Western Colorado Congress The Wilderness Society 134 N. 6th St. 1660 Wynkoop St., Suite 850 Grand Junction, CO 81501 Denver, CO 80202 (970) 256-7650 (303) 468-1961 [email protected]
Sloan Shoemaker Tehri Parker Executive Director Executive Director Wilderness Workshop Rocky Mountain Wild PO Box 1442 1536 Wynkoop St., Suite 900 Carbondale, CO 81623 Denver, CO 80202 (970) 963-3977 (720) 446-8582 [email protected] [email protected]
Robyn Cascade, Co-Leader Tim and Sheri Murphy Northern San Juan Chapter/Ridgway, CO 109 Grizzly Peak Dr. Great Old Broads for Wilderness Almont, CO 81230 PO Box 2924 (720) 233-1432 Durango, CO 81302 [email protected] (970) 385-9577 [email protected]
James E. Lockhart, President Allison N. Melton Wild Connections Staff Attorney 2168 Pheasant Place Public Lands Program Colorado Springs, CO 80909 Center for Biological Diversity (719) 385-0045 PO Box 3024 [email protected] Crested Butte, CO 81224 (970) 309-2008
Attachment 1 - Reducing the Wildland Fire Threat to Homes: Where and How Much?
Attachment 2 - The Wildland-Urban Interface Fire Problem, A Consequence Of The Fire Exclusion Paradigm
Attachment 3 – Mountains to Mesas. Conservation Management Alternative For Protecting Biological Diversity and Ecosystem Health on the Grand Mesa, Uncompahgre, and Gunnison National Forest
Attachment 4 - The Influence of Dwarf Mistletoe on Bird Communities in Colorado Ponderosa Pine Forests
Attachment 5 - Seasonal Resource Selection of Canada Lynx in Managed Forests of the Northern Rocky Mountains
Attachment 6 – Photos Taken by HCCA Staff on May 19, 2018